On August 27, 2020, the Office of Head Start (OHS) released a Program Instruction (PI) announcing changes to DRS that were published in a Final Rule. This announcement is important for all Head Start/Early Head Start grantees, and particularly important for grantees that anticipate competing for funding in the upcoming round of DRS.

There are seven conditions of DRS, and three of those conditions are updated with the Final Rule: Deficiency Condition, CLASS Condition, and Fiscal Condition. Below are brief summaries of the changes, which will be effective October 27, 2020. We recommend you review the PI and Final Rule for complete information about the changes.

Deficiency: If grantees receive two deficiencies they will be required to compete for funding in DRS. This is a change from the threshold of one deficiency that is currently in place.

CLASS: The lowest 10% criterion is removed and, instead, quality thresholds and competitive thresholds are established for each domain. The new competitive thresholds are 5 for Classroom Organization (raised from 3); 5 for Emotional Support (raised from 4); and 2.3 for Instructional Support (raised from 2). The Instructional Support threshold is effective for reviews conducted through July 31, 2025. After that, the minimum threshold will be 2.5.

Fiscal: Grantees will continue to be required to compete for funding if an ongoing concern is identified in an audit report. A second criterion was added that, as the PI states, “requires competition if a grantee has a total of two or more audit findings of material weakness or questioned costs related to their Head Start funds in audit reports for a financial period within the current project period.”

If your program received a determination letter for the upcoming round of DRS, the PI states that your program will be required to compete if it would also be required to compete under the revised conditions. In other words, if your program meets the current conditions for DRS but does not meet the new conditions then you may no longer need to complete (e.g., your program has one deficiency). Following is the relevant section of the PI.

For all grantees that have been designated for competition under the prior conditions and a funding opportunity announcement (FOA) has not been posted, OHS will reexamine the existing data to determine if they also meet the revised conditions. The new second criterion added to the fiscal condition will not be considered. These grantees will be required to compete if they would also be required to compete under the revised conditions. OHS will send redetermination letters to this group of grantees either reconfirming their competitive status or notifying them of preliminary eligibility for non-competitive funding.

The updates to DRS are significant, and this may change the course of competitive or non-competitive grant writing for many grantees this fall.

Foundations for Families offers a variety of supports to programs in DRS through our Grant Writing Solutions. This includes comprehensive grant writing, in which Foundations for Families team members provide customized support from start to finish to help applicants plan, draft, and submit a high-quality, competitive grant application. We also offer grant coaching, quality assurance reviews, grants.gov submission support, and a DRS toolkit to guide you through the process. Contact us to learn more and find out which approach is the right fit for your program.

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